35 replies to this topic

[Esther]

Hello all

I am not a person with a food allergy but I can understand that this can be a serious potencial health problem for people who has one.

I think that the premise a person with a food allegy should always have in mind is: " Nobody can take care of you but you". A person with a food allergy should ensure that he/she knows what food contains that allergen, what food is likely to contain that allergen and also should read the label ( it may help ).

On the other hand, about considering an allergen as a hazard or a CPP, in a systematic way
does it make sense to consider an allegen as a hazard in a meat cutting plant or meat processeng plant with no vending machines and no canteens ?

When starting doing a HACCP plan or auditng a HACCP, we should first think in the whole process in " that " plant,and then, and only then, consider if there is or not a allegenic risk.

So, I would like to know if an ISO 22000 auditor would write a non compliance if an allegen is not consider as a CCP ,or even not mentioned, in the food premise above ?

Hoping to hear from you

Sincerely
Esther

[Charles.C]

Dear Esther,

Yr post contains a nice variety of topics. I felt yr expectation of personal self-protection although perhaps sadly realistic is far too generous to the manufacturing industry.

Not currently an auditor but can offer some thoughts –

Meat allergies – I suppose it all depends on the particular meat / process, assuming you are looking at the broad picture. Some possible allergenic relevances are discussed here –

http://www.access4al...at-allergy.html
http://www.labspec.co.za/l_meat.htm
http://www.mda.state...als/default.htm

Since ISO 22000 specifically remarks on allergens, I imagine no risk consideration at all would not be passed over. As discussed in some other threads here, seems that the tendency in “pure” HACCP is to handle allergenic aspects within the Prerequisite Program. This is arguable of course depending on yr point of view regarding HACCP / CCPs, allergen labelling is certainly used as a CCP by some HACCP modelers.

For ISO 22000 I haven’t seen any authoritative evaluations (anybody?).

Rgds / Charles.C

[Chac]

Hallo to all,
I never did a HACCP so far, but I asked in my company about it. The mention of "may content" is necessary if it is not mentionend in the ingridients list.
In my company they produces more than one type of product on the same machine. If they produce something that contains e.g. nuts and then they change the production to a product which does not include nuts they get in trouble. Of course they are cleaning the machine, they but the first products aside but they can´t gurantee that there are no traces at all. As is it mentioned before within nuts this could be mortal danger. I don´t think that this has something to do with can´t control the process.
As for HACCP I´d say it is better to put it as a CCP (it´s handled in that way in my company) but I don´t know if it is demanded.
Or could it be a disadvantage to you if you put unnecessary CCPs in your HACCP plan???
Does anyone knows about that?

By the way:
Some companys are overreacting with that allergen stuff: in Germany you can find peanuts with the hint " product may content traces of nuts" Since I´ve read this statement I don´t buy it any longer. If peanuts only "may content" nuts and if so only in "traces" then I´m wondering what I am actually eating.

Greetings Chac

[Esther]

Hello Charles

Thank you for your thoughts, very useful.

Personally I would handle it as a pre-requisite but I would like to know more opinions, comments or experiences.

And I would like to start with yours, Charles ?

Sincerely
Esther

[KellyB]

Hi all,
Let me try to contribute to this indeed very interesting subject, by giving you an idea of how we managed things in the company where I work (importing foodstuff from the Asian countries.... full of allergenics!)
First of all I must say that European law and also the Greek law request that we must state all the ingredients of a product that could cause an allergy on the label, under the list of ingredients. In addition to that there can be an extra phrase stating "This product contains (this or that allergenic)". So this is what we do.

Also, we ask our providers to give us a production flow-chart for every product and a list of all the raw materials that they use (generally) and to inform us if there is any possibility for a cross-contamination. In addition, we occasionaly send samples for analysis (if we suspect that there is a "hidden" allergenic. So we add the phrase "this product may contain traces of nut.... egg...." and so on.
But what happens with unpacked and unlabelled products like bread for instance? Bread sold in Greece is most of the times covered by sesame - and bread is not packed nor labelled, yet I suppose that people with an allergy to sesame must know that they can't eat it. I mean that people with an allergy MUST know what they are allergic to and MUST read the labels. It's not your responsibility to teach people that they must read the labels in order to know what they eat.

Concerning the HACCP/ISO, we DON'T consider allergenics is a CCP (just a hazard) BUT we consider that correct labeling is. What we also did (and the auditors were very persistant on checking it during our ISO audit) was to include the allergenic precaution under the term "USE OF PRODUCT" in every product's data sheet (we call it product specification) and to include the "product specification sheet" into our list on encoded-controlled documents.
I hope everyone understands what I mean.

I would also like to add a comment concerning the labelling of tuna with a warning "this product contains fish". It may sound funny, but not everybody understands that tuna is a fish (especially if you live in a place with a lot of tourists), but everybody understands what a fish is. We import a product from the Philippines called "Dillis" and we have this warning because most of the Greek consumers are not obliged to know that dillis is a kind of fish.

Concerning the limits of intolerance... no one can really tell. It depends on the person's biology. I have heard of someone that DIED because he eat something that was fried in a pan where soybean oil was used previously and it was not washed carefuly.
Also, we had a talk with a friend trying for months to find out where the egg was coming from on some of their pasta products, since they have two separate production lines in two separate rooms....(one for the products with egg and another for the ones without egg)... well, they found out that there was some egg powder remaining on the sleeves of some of the workers who were passing from the one room to the other... And they ended up by separating the workers as well!

Greetings everyone!
Kelly

[Simon]

Hi all,
Let me try to contribute to this indeed very interesting subject, by giving you an idea of how we managed things in the company where I work (importing foodstuff from the Asian countries.... full of allergenics!)
First of all I must say that European law and also the Greek law request that we must state all the ingredients of a product that could cause an allergy on the label, under the list of ingredients. In addition to that there can be an extra phrase stating "This product contains (this or that allergenic)". So this is what we do.

Also, we ask our providers to give us a production flow-chart for every product and a list of all the raw materials that they use (generally) and to inform us if there is any possibility for a cross-contamination. In addition, we occasionaly send samples for analysis (if we suspect that there is a "hidden" allergenic. So we add the phrase "this product may contain traces of nut.... egg...." and so on.
But what happens with unpacked and unlabelled products like bread for instance? Bread sold in Greece is most of the times covered by sesame - and bread is not packed nor labelled, yet I suppose that people with an allergy to sesame must know that they can't eat it. I mean that people with an allergy MUST know what they are allergic to and MUST read the labels. It's not your responsibility to teach people that they must read the labels in order to know what they eat.

Concerning the HACCP/ISO, we DON'T consider allergenics is a CCP (just a hazard) BUT we consider that correct labeling is. What we also did (and the auditors were very persistant on checking it during our ISO audit) was to include the allergenic precaution under the term "USE OF PRODUCT" in every product's data sheet (we call it product specification) and to include the "product specification sheet" into our list on encoded-controlled documents.
I hope everyone understands what I mean.

I would also like to add a comment concerning the labelling of tuna with a warning "this product contains fish". It may sound funny, but not everybody understands that tuna is a fish (especially if you live in a place with a lot of tourists), but everybody understands what a fish is. We import a product from the Philippines called "Dillis" and we have this warning because most of the Greek consumers are not obliged to know that dillis is a kind of fish.

Concerning the limits of intolerance... no one can really tell. It depends on the person's biology. I have heard of someone that DIED because he eat something that was fried in a pan where soybean oil was used previously and it was not washed carefuly.
Also, we had a talk with a friend trying for months to find out where the egg was coming from on some of their pasta products, since they have two separate production lines in two separate rooms....(one for the products with egg and another for the ones without egg)... well, they found out that there was some egg powder remaining on the sleeves of some of the workers who were passing from the one room to the other... And they ended up by separating the workers as well!

Greetings everyone!
Kelly

Nice to hear your interesting information on the subject Kelly. Well worth the wait.

Regards,
Simon

[Charles.C]

Dear Esther and Kelly,

I confess to being not very enthusiastic about the concept of Prerequisites. I rather feel that they have been over-utilised to escape from the original risk analysis element within HACCP.

(I liked the partially analogous but more restrictive format of the aging US / SSOP style and particularly the in-depth analyses of the meaning of such parameters as particularly provided for the seafood business.)

Admittedly my opinion is certainly not very mainstream at the moment and often clashes with auditorial expectations however I still prefer the focus attained (Luckily, I also enjoy arguing with auditors !)

This obviously has some personal negative implications with respect to ISO 22000 also.

@Kelly – As Simon noted, so good to hear from you again, hopefully recovered from ISO 22k grilling (seem to remember something about data prps/ oprps ??). Yr comments illustrate there is no substitute for positive/negative experiences.

“Also, we ask our providers to give us a production flow-chart…..” The request is easy, the obtainance is like going to the dentist’s IMEX.

“It's not your responsibility to teach people that they must read the labels in order to know what they eat.” – Sorry, I don’t agree and I think HACCP supports me, conceptually anyway.

“I would also like to add a comment concerning the labelling of tuna with a warning ‘this product contains fish’” – Actually there is another post in this forum using this precise example to demonstrate the height of idiocy that labeling has now reached. I suppose “dilis” half proves yr point, it sounds like a herb to me, but whether “mystery” non-labeling represents an automatic safety risk?. I suppose to maintain my axiom above, yes it does, might have been petfood.

Rgds / Charles.C

[just me]

Many thanks to Susan for the wonderful reference.

IMO, labelling may be a CCP in terms of addressing allergens, we have seen so many recalls just because of wrong labelling.

The term "May contain..." is useful in informing consumers, we may need to think about the risk of cross-contamination between different lines.

Most of us are discussing about controlling allergens in the manufacturing industries, ever wonder how the control need to be the F & B (hotel and restaurants) industry?

Imagine the chefs needing to have in-depth knowledge on the ingredients of each materials that is being used in the kitchen.
Imagine the risk of cross contamination of allergen in a kitchen.

I get frowns all the time from chefs at my area of work. I imagine them imagining how to control it.

[KellyB]

... trying to reply to the above and with my line being cut twice,
what I would like to say Charles, is that yes, indeed I am still recovering and also I haven't forgotten my promise to let you know how our audit procedure was. I will find some time and give you a full report (I guess that the auditor in you is quite curious).
Concerning our providers... it may sound surprisining but indeed they do give us the production flow-charts, since it is very clear to them that its for their best interest
And by saying that it's not our responsibility to teach people that they must read the labels, I simply meant that there is no such law. It's just a matter of general education and on how responsibly we all act. Our responsibility is to provide all the necessary information clearly and truthfully on the product's label. Whether people care to read what is written on the labels... I strongly believe that most of the consumers don't!

Now, concerning allergies, take a GOOD look at this:
http://ec.europa.eu/...m_legisl_en.htm

and especially this :

"The new Directive also establishes a list of ingredients liable to cause allergies or intolerances; alcoholic beverages will also have the obligation to mention allergens on their labels.
These new provisions will be fully implemented as from 25 November 2005.
...................................
...................................
However, since it is possible that some ingredients or substances, derived from allergens, are not likely to be a risk for allergic peoples, the Directive establishes, during a transitional period, a procedure which allows the industry to provide scientific justification for that, and to obtain a provisional labelling exemption for these ingredients or substances.
Guidelines have been adopted by the Commission's services for the implementation of this procedure. Commission Directive 2005/26/EC, establishing a list of substances provisionally exempted, has been adopted by the Commission on 21st March 2005, following EFSA's opinions on each request.
These provisional exemptions are granted until 25 November 2007....."

Comments anyone?
Rgrds/Kelly

[Esther]

Hello KellyB

Quite agreed with your comments.

Once I was shocked filling in a client questionnare. The client knows that we are a fish processing company and, even so, on the ingredients list of the questionnaire you can read: fish ? Personally, as a consumer, I would never buy something to eat if I do not what it is or at least if I do not know if it comes from agricultural kingdom, fishety/sea kingdom or land/ farm kingdom. How to get the information ? I would ask the sender. Anyway, it is also easily if you can read it somewhere on the pack-


Just curious; you mentioned an ISO audit, but I was wondering if your company has implemented a Food Safety management system such as BRC, IFS, SQF, ISO 22000 or perhaps some other recognized in Greece ?

sincerely
Esther

[Jean]

A very interesting thread and useful refernce from Susan. The customers should help themselves by reading the label if they are allergenic to any foods. If a customer who is dining from any restaurant and is allergenic to any foods should inform the staff and should ask for the ingredients in any dish before consuming. Similarly the service and kitchen staff should be trained on the types of allergens, the various ingredients present in the foods which can cause a allergic reaction or cross reaction. The staff should be trained on how to avoid any cross contamination during preparation, handling and serving also to ensure the utensils or crockery are cleaned thoroughly before preparing the dish for the allergic person.